OSHA Pushes HCS Deadlines Back Four Months

On May 20, 2024, the Occupational Safety and Health Administration (OSHA) finalized updates to the Hazard Communication Standard (HCS). Paragraph (j) of the HCS establishes the compliance deadlines for the revised requirements. OSHA adopted a tiered compliance approach and set two phases of deadlines for chemical manufacturers, importers, and distributors evaluating substances and mixtures (see 29 CFR 1910.1200(j)).

Why OSHA Extended the Original Compliance Deadline

The initial compliance deadline in §1910.1200(j)(2)(i)—January 19, 2026—for manufacturers, importers, and distributors evaluating substances was approaching rapidly. Members of the regulated community requested additional guidance to support compliance with the revised HCS. While OSHA has been developing guidance materials for both regulated entities and agency personnel, the agency determined that these materials could not be finalized in time to be useful before the original deadline.

As a result, OSHA concluded that extending the initial compliance date by four months was necessary to allow time for publication and review of the guidance materials before the updated provisions take effect. To preserve the tiered compliance structure adopted in the final rule, OSHA also extended all subsequent compliance deadlines by four months.

OSHA’s Formal Announcement of the Extension

On January 15, 2026, OSHA formally announced the extension of the compliance dates associated with the updated Hazard Communication Standard. Manufacturers, importers, and distributors were originally required to evaluate certain substances by January 19, 2026; this deadline has now been extended to May 19, 2026. OSHA stated that the extension is intended to provide sufficient time for the agency to publish guidance materials and for the regulated community to review them before the revised requirements take effect. Additional details are available in the Federal Register notice.

Revised Compliance Dates Under the Hazard Communication Standard

§1910.1200(j)(2)(i): Extended from January 19, 2026, to May 19, 2026
§1910.1200(j)(2)(ii): Extended from July 20, 2026, to November 20, 2026
§1910.1200(j)(3)(i): Extended from July 19, 2027, to November 19, 2027
§1910.1200(j)(3)(ii): Extended from January 19, 2028, to May 19, 2028

What the Deadline Extensions Mean for SDS Compliance

In a prior ICC blog post, we provided a compliance chart based on OSHA’s earlier deadlines. All revised deadlines are four months later than those previously announced. For example, the compliance deadline for substance labels and SDSs is now May 19, 2026

Previous deadlines:

Although these deadlines have been extended, it remains critical to begin updating your Safety Data Sheets (SDSs) to ensure OSHA compliance. If you sell products in the United States and need assistance authoring U.S.- OSHA compliant SDSs, please contact us—we would be happy to support you. Existing clients who need previously authored SDSs updated can also rely on us for those revisions. Taking action now will help ensure you meet all applicable SDS compliance deadlines.

Contact our team today to ensure your SDSs align with OSHA’s revised HCS deadlines – call 855.734.5469 or send us an email, we’re happy to help.